United States Tax Court June 14, 1994, Docket No. 28342-91X (Paratransit Ins. Corp. v. Commissioner)

lead-opinion

OPINION

Raum, Judge:

The Commissioner determined that petitioner is not an organization described in section 501(c)(3)1 and that it is not exempt from Federal income tax under section 501(a) for the taxable year 1988 and subsequent years.